1. Overview
This Privacy Policy describes how Best Apps Tech (“we,” “our,” or “us”) collects, uses, discloses, and protects information when you use TwinPick (the “App”) and related services.
The App is designed to allow users to voluntarily upload photos for automated face analysis and to receive system-generated results. We aim to minimize data collection and to process only the information reasonably necessary to operate, secure, improve, and enforce the App.
This Privacy Policy is intended to align with our Terms of Use. By using the App, you acknowledge that information may be processed as described here.
2. Information We Collect
We do not require users to create an account or provide traditional registration information such as name, email address, phone number, postal address, or date of birth in order to use the App’s core functionality. However, we may collect and process the following categories of information:
- Device and technical information: such as IP address, device type, operating system, app version, language settings, time zone, network information, crash logs, and error diagnostics.
- Usage and service information: such as feature interactions, request timestamps, response status, entitlement checks, anti-abuse signals, and service reliability metrics.
- Transaction-related information: such as purchase status, subscription or entitlement status, transaction identifiers, receipt validation data, chargeback or refund status, and limited billing support information.
- User-submitted content: including photos that you voluntarily upload for analysis and any support messages or materials you submit to us.
We do not store full credit card numbers, card security codes, or other full payment card credentials on our own systems.
3. Uploaded Photos and Face-Related Data
When you choose to use the App’s core features, you may upload photos for automated face similarity analysis. These uploaded photos may contain faces and, depending on applicable law, may constitute personal data or biometric-related data.
In connection with the requested comparison feature, we process: (i) the uploaded photos themselves, (ii) face-related data temporarily derived from those photos as necessary to detect faces and measure facial similarity, such as temporary facial feature representations and similarity metrics, and (iii) limited technical metadata necessary to deliver, secure, and troubleshoot the service.
We process this face-related data solely to provide the user-requested face matching and similarity comparison result within the App. We do not use face-related data to identify a real-world person, verify identity, authenticate users, match against government records or external identity databases, or infer personal identity.
Uploaded photos and face-related data are:
- processed only in connection with the requested service;
- not used for advertising;
- not sold to third parties;
- not used for unrelated secondary commercial purposes;
- not used to create persistent user profiles; and
- not used to train machine learning or artificial intelligence models unless we separately obtain any legally required consent and update this Privacy Policy.
We do not share face-related data with third-party face recognition providers, biometric identification services, or identity-matching services. Face-related data may be processed and temporarily stored on our servers and by cloud hosting or infrastructure providers acting solely on our behalf for the limited purpose of operating the App and storing data during the retention period described in this Privacy Policy. The servers used for this processing and temporary storage are located in the United States.
Uploaded photos and associated face-related data are automatically deleted within 48 hours after upload, subject to limited exceptions where longer retention is reasonably necessary to comply with law, respond to legal process, resolve a security incident, investigate fraud, preserve evidence of abuse, protect our rights, or complete an active technical incident review.
4. How We Use Information
We use information only for legitimate business and operational purposes, including to:
- provide, operate, and maintain the App and its face-analysis functionality;
- process uploaded photos and return the requested results;
- authenticate purchases, verify entitlements, and manage access to paid features;
- detect, prevent, investigate, and respond to fraud, chargebacks, abuse, unauthorized activity, technical misuse, and security incidents;
- troubleshoot crashes, bugs, service interruptions, and compatibility problems;
- monitor service performance, integrity, and reliability;
- communicate with users about support requests, legal notices, material policy updates, or service-related issues; and
- comply with legal obligations and enforce our Terms of Use and other rights.
We do not use uploaded photos for advertising, data brokerage, unrelated profiling, or unrelated commercial exploitation.
5. Legal Bases for Processing
Where applicable law requires a legal basis for processing, we rely on one or more of the following:
- Performance of a contract: where processing is necessary to provide the App and requested services to you.
- Legitimate interests: where processing is reasonably necessary for service security, fraud prevention, diagnostics, operational stability, internal administration, rights protection, and enforcement.
- Compliance with legal obligations: where processing is necessary to comply with law, lawful requests, accounting duties, or regulatory requirements.
- Consent: where consent is required by law for a particular processing activity.
7. Retention and Deletion
We retain information only for as long as reasonably necessary for the purposes described in this Privacy Policy, taking into account the nature of the data, the reason it was collected, legal requirements, and operational needs.
- Uploaded photos and associated face-related data: automatically deleted within 48 hours after upload, unless a limited exception described in this Policy applies.
- Technical logs and diagnostics: retained only for as long as reasonably needed to troubleshoot, secure, audit, monitor, and improve service reliability or investigate abuse.
- Transaction-related records: retained for as long as reasonably necessary for billing support, refunds, fraud prevention, dispute resolution, accounting, tax, legal, and compliance purposes.
- Support communications and enforcement records: retained as reasonably necessary to resolve requests, preserve evidence, handle claims, or comply with law.
Where appropriate, we may delete, aggregate, or de-identify information so that it can no longer reasonably be associated with an individual.
8. Security, Fraud Prevention, and Enforcement
We use reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, disclosure, alteration, loss, or destruction. These measures may include access controls, logging, service monitoring, internal review procedures, and other safeguards appropriate to the nature of the information.
We may process information to detect, prevent, investigate, and respond to suspected fraud, abuse, chargebacks, service misuse, unlawful activity, and security incidents. In appropriate circumstances, we may preserve relevant records or evidence, review technical logs, limit or suspend access, remove content, cancel entitlements, or cooperate with regulators, law enforcement, platforms, payment providers, or other relevant parties.
No method of transmission over the internet or electronic storage is completely secure, so we cannot guarantee absolute security.
9. International Data Transfers
Because the App may be offered in North America, Oceania, Europe, and parts of Asia, information may be processed or stored in countries other than the country where you reside.
Where required by applicable law, we implement appropriate safeguards for cross-border transfers, which may include contractual protections, internal procedures, or other lawful transfer mechanisms.
10. Your Privacy Rights
Depending on your location and applicable law, you may have rights regarding your personal data, including the right to request access, deletion, correction, restriction, objection, withdrawal of consent where applicable, and to lodge a complaint with a relevant supervisory authority.
Because the App does not require account registration and does not maintain long-term identity profiles for ordinary use, the amount of information we can reasonably associate with a particular user may be limited. In particular, uploaded photos may already have been deleted by the time we receive your request.
To exercise applicable rights, please contact us at contact@bestapps.software. We may request reasonable information to verify your request, confirm your relationship to the data, protect against fraudulent or abusive requests, and determine whether an exception or lawful basis allows or requires us to retain or continue processing certain information.
11. Children’s Privacy
The App is not directed to children under 13, or under any higher minimum age required by applicable law. We do not knowingly collect personal data from children in violation of applicable law.
If you believe that a child has provided personal data through the App in violation of applicable law, please contact us and we will take reasonable steps to review the issue and respond appropriately.
12. Third-Party Services and Platforms
The App may rely on third-party services or platforms, including app stores, hosting providers, payment processors, infrastructure providers, crash diagnostic tools, and security or analytics vendors. Those third parties may process information under their own terms and privacy policies.
We are not responsible for the privacy, security, availability, or practices of third-party services that we do not own or control. We encourage you to review their applicable policies where relevant.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in law, the App, our business practices, service providers, technical operations, or risk management needs. The updated version will become effective when posted, unless a later date is stated.
Where required by law, we will provide additional notice or obtain any required consent before a change becomes effective.
14. Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us:
Developer Name: Best Apps Tech
Email: contact@bestapps.software